New Delhi

The Delhi High Court has dismissed a rectification petition filed by Holy Cow Foundation, holding that the trademark "PATANJALI GONYLE FLOOR CLEANER" is validly registered and does not deceptively resemble the petitioner's mark "GAUNYLE."

The Court concluded that the petitioner failed to establish prior and continuous use of its mark and that the presence of the well-known house mark "Patanjali" sufficiently distinguishes the respondent's product in the marketplace.

In a detailed judgment delivered on January 9, 2026, Justice Tejas Karia found serious inconsistencies in the documentary evidence relied upon by the petitioner to claim usage of "GAUNYLE" since 2013.

The Court noted that invoices produced by the Holy Cow Foundation contained chronologically improbable dates, casting doubt on their authenticity and undermining the claim of prior user rights under Section 34 of the Trade Marks Act.

Rejecting the allegation of deceptive similarity, the Court observed that while "GAUNYLE" and "GONYLE" may bear some phonetic resemblance, the impugned mark must be assessed as a whole. It held that the prominent use of the well-known house mark "PATANJALI" in Patanjali Gramodyog Nyas's product clearly indicates its source and is unlikely to confuse an average consumer of ordinary intelligence and imperfect recollection.

The Court also took note of the fact that Patanjali Gramodyog Nyas had applied for registration of the impugned mark in August 2015, prior to the Holy Cow Foundation's application filed in December 2015.

Even on application dates alone, the respondents enjoyed priority, the judgment said, adding that the petitioner had not opposed the registration at the relevant stage.

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Concluding that the conditions for rectification under Section 57 read with Sections 9 and 11 of the Trade Marks Act were not satisfied, the High Court held that the continued registration of "PATANJALI GONYLE FLOOR CLEANER" does not cause deception or confusion. The rectification petition was accordingly dismissed, and the trademark was directed to remain on the register, with no order as to costs.